Leveo Privacy Policy

If you are in the UK:

Financewell Limited (d/b/a Leveo) with registered address T Bromley, 15 London Road, Bromley, Kent, England, BR1 1DE, and whose ICO registration number is ZA487066

(together with our aﬃliated companies – “Leveo” , “we” , “our” or “us”) puts great eﬀorts in making sure that your personal data is kept safe and used properly and responsibly. We oﬀer Master Broker services to Introducers, Borrowers and Lenders who oﬀer loan solutions, secured against a wide range of assets including buy-to-let and commercial properties, land (with or without planning) and properties requiring refurbishment or change of use (our “Services”).

This Privacy Policy describes how we collect, store, use and disclose the following types of personal data:

Borrower Data relating to individuals or companies who are borrowers or potential borrowers of our aﬃliates Novellus Finance Limited and Novellus Limited (“Borrower(s)”);
Introducer Data relating to individuals who engage with Leveo and its aﬃliates and may provide personal data regarding potential Borrowers (“Introducer(s)”);
Lender Data relating to individuals (employees and contact people) who are employed by Lenders or contacted by Leveo on behalf of Lenders (“Lender Employees”).
Sites Usage, Customer Relationship Management (“CRM”) & Prospect Data, relating to visitors of our website, participants at our events, Borrowers, partners, and any prospective Borrower and Introducer who visits or otherwise interacts with any of our websites, online ads and content, emails or other communications under our control (“Leveo Sites” or “Sites”).

Specifically, this Privacy Policy describes our practices regarding the following with respect to our Services:

1. Data Collection

2. Data Uses

3. Data Location and Retention

4. Data Sharing

5. Cookies and Tracking Technologies

6. Communications

7. Data Security

8. Data Subject Rights

9. Data Controller/Processor

10. Additional Notice & Contact Details

If you are Borrower, Introducer, Lender Employee or Site visitor (“you”), please read this Privacy Policy carefully and make sure that you fully understand and agree to it.

You are not legally required to provide us with any personal data, and you are free to do so or not to do so. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please refrain from using our Services or sending us your personal data.

1. DATA COLLECTION

(i) Borrower Data: we may collect the following types of personal data relating to borrowers (“Borrower Data”):

Personal Data: full name, date of birth, nationality, passport number, contact details (e-mail address, mobile number), postal address and further information relating to residence (e.g. owned or rented and time at previous address – if the individual resided less than three years at the current address).
Employment History Data: employment status, employer name, nature of business, length of time employed/self-employed.
Financial Data: Credit history, mortgage status, bank account information, bankruptcy, Individual Voluntary Arrangement, court judgments, and other information which may impact the Borrower’s creditworthiness.
Direct Interactions and Communications Data: recordings and transcripts of your calls, emails, form submissions and chats with us, e.g. for customer support, feedback etc.
In the case of a corporate Borrower, in addition to the information listed above, we may also collect Director/Shareholder Data: full name, date of birth, nationality, contact details (e-mail address, mobile number), address and further information relating to residence (e.g. owned or rented, time at previous address) and shareholding percentage.

(ii) Introducer Data: we may engage with Introducers and receive information relating to potential Borrowers form them.

We may collect and generate the following types of personal data relating to Introducers (“Introducer Data”):

Personal Data: full name, contact details (e-mail address, mobile number, etc).
Direct Interactions and Communications Data: including recordings and transcripts of Introducer’s calls, emails, form submissions and conversations with us, e.g. for customer support, feedback, training purposes, etc.

(iii) Lender Data: we may engage with Lenders and engage with Lender Employees.

We may collect and generate the following types of personal data relating to Lender Employees (“Lender Data”):

Personal Data: full name, contact details (e-mail address, mobile number, etc).
Direct Interacttions and Communications Data: including recordings and transcripts of Lender’s calls, emails, form submissions and conversations with us, e.g. for customer support, feedback, training purposes, etc.

(iv) Sites Usage, CRM & Prospective Borrower Data, and Human Resources Data: we may collect and generate the following types of personal data concerning our website visitors, partners, Introducers, Borrowers and prospective Borrowers (collectively, “Non-Services Related Data”):

Sites Usage Data – connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like device type, OS, device ID, browser version, locale and language sekings used), activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites and/or a user’s device;
Business Account Data – contact details, contractual and billing details relating to our vendors, which may also contain the details of their internal personnel who directly engage with Leveo on behalf of their organization (e.g. the account administrators, billing contacts and authorized signatories on behalf of the vendor, as well as their needs and preferences, as identified to us or recognized via our engagement with them);
CRM and Prospective Borrower Data – contact and business details, our communications with Borrowers and prospective Borrowers (correspondences, call and video recordings, call transcripts, and analyses thereof), as well as any needs, preferences, anributes and insights relevant to our potential engagement;
Human Resources Data – contact, business and personal details regarding Leveo job applicants, CVs, photographs and our communications with job applicants (correspondences, call and video recordings, call transcripts), as well as evaluations and feedback following interviews and other interactions with us.

We collect the above Non-Services Related Data either automatically, through your interaction with us (via email, virtual or telephone calls), or with our Sites or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives. To the extent that any of the above-mentioned data pertains only to a non-human entity (e.g., the phone number or bank account of a company or business), we will not regard it as “personal data” and this Privacy Policy will not apply to it.

2. DATA USES

We use personal data as necessary for the facilitation and performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services; providing customer service and technical support; and protecting and securing Borrowers, Introducers, Lenders, partners, as well as Leveo itself and its Service.

Further detail about the legal basis on which we rely for each type of processing can be found in the table below.

BORROWER, INTRODUCER & LENDER DATA

PURPOSE

LEGAL BASES FOR PROCESSING

Provision of our Services

Performance of a contract
Legitimate Interest

To comply with applicable laws and regulations

Compliance with a legal obligation

Sending marketing communications

Legitimate Interest
Consent where necessary

To support and enhance our data security measures, including for
preventing and mitigating the risks of fraud, money laundering, error or
any illegal or prohibited activity.

Legitimate Interest
Compliance with legal obligations

To create aggregated data, inferred non-personal data or anonymized or
pseudonymized data (de-identified data), which we or our business
partners may use to provide and improve our respective Services,
conduct research, or for any other purpose

Legitimate Interest

N ON-SERVICE-RELATED DATA

PURPOSE

LEGAL BASES FOR PROCESSING

To facilitate, operate, and provide our Service

Legitimate Interest
Performance of a Contract

To provide our visitors, Users, Borrowers, Introducers and Lenders with
assistance and support.

Legitimate Interest
Performance of a Contract

To facilitate and optimize our marketing campaigns, ad management and
sales operations, and to manage and deliver advertisements for our
products and services more effectively, including on other websites and
applications.

Legitimate Interest

To evaluate and develop new features, technologies, and improvements of our Services.

Legitimate Interest

To contact our Site visitors, Borrowers Introducers and Lenders (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them.

Legitimate Interest
Consent where necessary

To facilitate, sponsor and offer certain events, contests and promotions.

Legitimate Interest
Consent where necessary

To publish your feedback and submissions to our Sites, public forums
and blogs.

Legitimate Interest
Performance of a Contract
Consent where necessary

To support and enhance our data security measures, including for the
purposes of preventing and mitigating the risks of fraud, error or any
illegal or prohibited activity.

Legitimate Interest

To create aggregated data, inferred non-personal data or anonymized or
pseudonymized data (de-identified data), which we or our business
partners may use to provide and improve our respective services,
conduct research, or for any other purpose.

Legitimate Interest
Performance of a Contract
Compliance with legal obligations

To comply with applicable laws and regulations.

Compliance with legal obligations

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data, your acceptance of this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy. If you wish to revoke your consent, please refrain from using our Services and contact us at [email protected].

3. DATA LOCATION & RETENTION

Data Location: Your personal data may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the United States, Europe and the United Kingdom, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Leveo and its service providers are each commined to protect personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. These may include transferring your personal data to a country which is considered to provide an ‘adequate’ level of protection to your personal data, or puking in place standard contractual clauses and, if necessary, additional security measures to ensure your personal data is protected.

Data Retention: We will retain your personal data for as long as it is reasonably necessary for us to maintain our relationship with you and provide you with our Services and oﬀerings; in order to comply with our legal and contractual obligations; or to protect ourselves from, or defend, any potential or actual disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise), all in accordance with our contractual terms and data retention policy. Generally speaking, we will hold Borrower Data (and any data related to financing we have provided) for a period of 5 years following the end of a contract.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any Mme, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at [email protected].

4. DATA SHARING

Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement oﬃcials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement) and where such disclosure is necessary to comply with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; or (b) disclosure is appropriate in connection with eﬀorts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services.

Service Providers: We engage selected third-party companies and individuals to perform services complementary to our own. Such service providers hosting and server co-location services, communications and content delivery networks (“CDNs”), billing and payment processing services, data and cyber security services, fraud detection and AML prevention services, web analytics, e-mail, text messages and web/mobile notification distribution, monitoring and analytics services, marketing services, document storage (e.g. SharePoint), collaboration and backup (e.g. Dropbox) services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“).

These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our agreements with them. Should you decide to directly engage with any of our Service Providers, please note that such engagement will be governed by the Service Provider’s terms and policies.

Third Party Websites and Services: Our Services may also include links to third-party websites, and integrations with third party services. These websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by the third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services.

Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Leveo, any of our Borrowers, partners, vendors, or any members of the general public.

Our Subsidiaries and Aﬃliated Companies: We may share personal data internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should we or any of our subsidiaries or aﬃliates undergo, or propose to undergo, any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of our assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially aﬀect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail.

For the avoidance of doubt, we may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

5. COOKIES & TRACKING TECHNOLOGIES

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are “Session Cookies”. Some last for longer periods and called “Persistent Cookies”. We use both types.

We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using certain parts of features of the Services.

For more information, please review our Cookie Policy.

We also use analytics tools such as Google Analytics. These tools help us understand your behaviour on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our google analytics is available at: www.google.com/ policies/privacy/partners/;

Further information about your option to opt-out of google analytics services is available at: https:// tools.google.com/dlpage/gaoptout.

Please note that if you get a new computer or device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

6. COMMUNICATIONS

Service Communications: We may send you notifications (through any of the means available to us, including by email, SMS and mobile notifications) of changes or updates to our Services, billing issues, service changes, etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to how we operate our Services (for example, payment notices).

Promotional Communications: We may also notify you about additional loan oﬀerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, SMS, mobile notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

7. INFORMATION SECURITY

We and our hosting services implement systems, applications and procedures to secure your personal data, and to reduce the risks of theft, damage, loss of data, or unauthorized access or use of personal data. These measures provide sound industry standard security. However, although we make eﬀorts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

8. DATA SUBJECT RIGHTS

Individuals have rights concerning their Personal Data. If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (“GDPR”) or the UK GDPR, such as the right to request access to, and rectification or erasure of your Personal Data held by Leveo, or to restrict or object to your Personal Data’s processing, or to exercise your rights to portability with respect to your Personal Data or your right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us at: [email protected].

If you are in the EU you have the right to lodge a complaint with your local supervisory authority (e.g. in Ireland the Data Protection Commission by emailing [email protected] or, if you are in the UK, with the InformaMon Commissioner’s Oﬃce – https://ico.org.uk/make-a-complaint.

Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain verifying information to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to boner understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

We may redact from the data which we will make available to you, any personal data related to others.

9. ADDITIONAL NOTICES

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our website. The amended version will be eﬀective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay atention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to Leveo’s Services.

Our Services are not designed to be used by children under the age of 16: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best eﬀorts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at [email protected].

Data Protection Oﬃcer: Leveo has appointed Avishai Ostrin as our Data Protection Oﬃcer (“DPO”), for monitoring and advising on Leveo’s ongoing privacy compliance and serving as a point of contact on privacy maners for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Leveo, please contact our DPO at [email protected].

Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact us at: [email protected].

Eﬀective Date: 22 October, 2024.